#tax-planning
Стратегическо данъчно планиране за минимизиране на задълженията и максимизиране на спестяванията
Section 1248 recharacterizes part of a U.S. shareholder's gain on the sale of CFC stock as a dividend, capped by the corporation's earnings and profits and reduced by PTEP from GILTI and Subpart F inclusions. This guide explains who is affected, how the lookback works, why corporate sellers can prefer the recharacterization for Section 245A, and how to build a defensible work paper.
Revenue Procedure 2019-38 lets landlords treat rental real estate as a trade or business for the 20% QBI deduction if they log 250 hours of qualifying services, keep contemporaneous records, avoid triple net leases, and file a signed election — now permanent under the 2025 One Big Beautiful Bill Act.
Rev. Proc. 2019-38 lets landlords claim the 20% QBI deduction if a rental enterprise logs 250+ hours of rental services a year with contemporaneous records and a signed election. Triple net leases and personal-use property are excluded.
A practical guide to Section 302 stock redemptions in closely-held C corporations — when a buyback gets capital gain treatment versus dividend treatment, how Section 318 family attribution disqualifies most family redemptions, and how the four 302(b) tests plus the 302(c)(2) waiver preserve sale treatment.
Section 302 of the Internal Revenue Code decides whether a closely-held C corporation's stock redemption is taxed as a capital sale or a full-amount dividend. This guide explains the three Section 302(b) tests, the Section 318 attribution traps that ensnare family-owned companies, the 10-year family-attribution waiver, and the partial-liquidation safe harbor under Section 302(b)(4).
Section 382 caps how fast an acquirer can use a target's net operating losses after an ownership change — annual limit equals the loss corporation's equity value times the long-term tax-exempt rate (about 3.58% in early 2026). Here is what triggers it and the legitimate workarounds.
Section 461(h) layers an economic performance test on top of the all-events test, so accrual-basis taxpayers cannot deduct a liability until the underlying activity actually happens. The recurring item exception accelerates deductions for predictable expenses when economic performance occurs within 8½ months of year-end and four specific conditions are met.
A Section 6603 deposit freezes IRS underpayment interest on contested tax while preserving your appeal, Tax Court, and withdrawal rights. This guide covers the written designation under Rev. Proc. 2005-18, when a deposit beats a payment, LIFO withdrawal mechanics, and the procedural traps that turn planned deposits into accidental payments.
A Section 6603 deposit halts interest on a disputed IRS liability without paying the tax, conceding the position, or forfeiting Tax Court access. Revenue Procedure 2005-18 spells out the mechanics—a written designation that names the tax, year, amount, and basis for disputability.
How Airbnb and Vrbo hosts classify income on Schedule E vs. Schedule C, calculate the 7-day average stay, and document material participation to unlock non-passive losses against W-2 wages.
A 2026 comparison of solo 401(k) and SEP-IRA plans for the self-employed, with contribution math at $60K, $120K, and $300K of net income, SECURE 2.0 Roth catch-up and super catch-up rules, setup deadlines, and a decision framework for picking the plan that shelters the most income.
A 2026 guide to ABLE accounts under IRC Section 529A — the new age-46 eligibility cutoff that makes 6 million more Americans (including 1 million veterans) eligible, the $19,000 annual contribution cap, the $100,000 SSI shelter, the unlimited Medicaid shelter, qualified disability expenses, the ABLE to Work multiplier up to $34,650, and how to avoid Medicaid clawback at death.
